Staff-only AI assistants: does an internal chatbot need an Article 50 disclosure?

Posted on Oct 28 • Originally published at mdodeja.github.io

This guide was drafted by an AI agent from the primary sources linked at the bottom, and has not been reviewed by a lawyer. It is general information, not legal advice. The original is at https://mdodeja.github.io/eu-ai-act-article-50-guide/guides/staff-only-ai-assistants-article-50.html.

Short answer. Article 50(1) is not limited to customers. It covers any AI system meant to interact directly with natural persons, and employees are natural persons. In practice most internal assistants are already obviously AI (staff open a tool called "AI assistant"), and the Act exempts that case. The internal cases that still need care are bots that pass messages as if from a person, AI voice or video that resembles real colleagues, and the separate AI literacy duty in Article 4.

Article 50(1) says providers must design AI systems "intended to interact directly with natural persons" so that the people concerned are informed they are interacting with an AI system. Nothing in it limits the duty to consumers or the public. A staff member asking an HR chatbot about leave is a natural person interacting with an AI system.

There is also no general exemption for internal use. "Putting into service" includes supplying an AI system for your own use in the EU (Article 3(11)), so a company that builds an assistant for its own staff can be its provider as well as its deployer.

The same paragraph has a built-in exception: no disclosure is needed where the AI nature is obvious "from the point of view of a natural person who is reasonably well-informed, observant and circumspect, taking into account the circumstances and the context of use".

The safe pattern is the same as for a customer chatbot: name the tool as AI and say so in the first message. It costs one line, and it removes the argument about what is obvious.

Under Article 50(1) the duty is the provider's: whoever builds the assistant, or has it built and puts it into service under its own name. For an off-the-shelf tool such as an enterprise chatbot product, that is the vendor, and those products usually present themselves as AI. For an assistant your own team built on a model API, your company is likely the provider, so the disclosure is yours to design in.

AI voice or video of real colleagues. Article 50(4) requires deployers of an AI system that generates or manipulates image, audio or video content constituting a deep fake to disclose that the content is artificially generated or manipulated. Unlike the text rule in the same paragraph, that sentence does not depend on the content being published to the public. An AI avatar of your CEO in an onboarding video, or a cloned voice of a trainer, resembles real persons and could pass as authentic, so label it. The deep fake guide covers the definition.

AI-written internal text. The Article 50(4) text duty covers text "published with the purpose of informing the public on matters of public interest". Internal memos, policies and newsletters to staff are not published to the public, so that duty does not apply to them. Labelling them can still be good practice.

Emotion recognition at work. Article 50(3) requires deployers of emotion recognition systems to inform the people exposed. Separately, Article 5(1)(f) prohibits emotion recognition in the workplace except for medical or safety reasons. If an internal tool claims to read staff mood from voice or video, check Article 5 first.